ARRL General Bulletin ARLB021 (2002)

ARLB021 Comments in SAVI proceeding bolster ARRL position

QST de W1AW  
ARRL Bulletin 21  ARLB021
From ARRL Headquarters  
Newington CT  March 19, 2002
To all radio amateurs 

ARLB021 Comments in SAVI proceeding bolster ARRL position

The ARRL says the large number of comments filed by amateurs in
opposition to SAVI Technology's plans to operate RF identification
tags on 70 cm support the League's position that the proposed rules
are flawed and should not be adopted. The ARRL took note of the
amateur community's response in its reply comments filed in the
proceeding, ET Docket 01-278, on March 12. SAVI wants the FCC to
authorize operation of the RFID system at 425-435 MHz at much higher
field strengths and duty cycles than current Part 15 rules permit
for such devices.

''There were approximately 132 comments filed by radio amateurs or
Amateur Radio organizations in this proceeding,'' the ARRL pointed
out, ''all of which are opposed to the proposal to allow high-power,
continuous-duty RFID tags and interrogators in the weak-signal
portion of the most popular and heavily-occupied UHF amateur band.''

RFID tags are used for tracking shipments and packages, among other
applications. While the ARRL said package tracking using RFID
technology ''is a beneficial application as a general matter,'' it
belongs elsewhere. The ARRL maintained that if the proposed rules
were enacted as proposed, the inevitable result would be severe and
harmful interference. Some commenters from the amateur community
predicted interference from--and to--the RFID tags as a result of
amateur TV operation in that portion of 70 cm. Others worried about
the tags' effects on weak-signal work.

''The only way to mitigate the interference in this case would be for
SAVI to select another band and abandon its plan for high-power,
high-duty-cycle operation at 425-435 MHz,'' the ARRL declared.

The ARRL admonished the FCC to ''not create Part 15 rules to
accommodate a single company's product or even one type of RF
device.'' The League also asserted that FCC approval of SAVI's
proposal would undermine the regulatory philosophy underlying the
current Part 15 rules governing unlicensed intentional radiators.
The ARRL reiterated its argument that the RFID tags cannot be
operated in the US under current Part 15 rules for unlicensed
devices and in numerous European and Asian countries cannot be
operated at all.

The ARRL's reply comments also characterized SAVI's tests and
interference studies as ''flawed'' and not representative of
real-world conditions.

Concluded the League, ''Operation of near-continuous duty devices at
Section 15.231(a) power levels at 433.92 MHz and the surrounding
band segment is fundamentally incompatible with incumbent amateur
operation and cannot be permitted.'' The ARRL again urged the FCC to
not adopted the proposals.

The ARRL's reply comments include a summary of the League's ex parte
presentation in the proceeding delivered to FCC Office of
Engineering and Technology staff members February 26.